Privacy Policy

Effective date as last modified: January 1, 2023

Introduction

FirstCall (“Company” or “We”) respects your privacy and is committed to protecting it through our compliance with this policy. We recognize information that may be confidential, proprietary or legally privileged and acknowledge that certain information may be protected under HIPAA, or other applicable regulations. FirstCall has policies and procedures that protect the confidentiality of your medical and personal information. These policies prohibit the sharing of any of your personal or medical information with anyone who does not have a right to know. The confidentiality policy, or HIPAA Notice of Privacy Practices, discloses your rights and is sent to all members. If you did not receive a copy and would like one sent to you or, should you have a question, please contact Customer Service at: info@firstcalltelemed.com.

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.firstcalltelemedicine.com (our “Website“) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy addresses issues set out in the California Consumer Privacy Act of 2018 (“CCPA”), and any terms defined in the CCPA have the same meaning when used in this policy.

Scope of Privacy Policy

This policy applies to information we collect:

• On or through this Website.
• In email, text, and other electronic messages between you and this Website or FirstCall.
• Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

This policy does not apply to information collected by:

• The Company offline or through any other means, including on any other website operated by the Company or any third party; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info@firstcalltelemed.com.

Information We Collect

Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). This personal information is stored and processed in Atlanta, GA, and in other locations for back-up and recovery purposes or to enable us to offer you certain services.

FirstCall’s Website and business operations have collected the following categories of personal information from its consumers within the last twelve (12) months:

The information we collect on or through our Website also may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting materials, or requesting further services. We may also ask you for information when you enter a promotion sponsored by us, and when you report a problem with our Website. For example, if you register on our Website, we collect your name, e-mail address and password. If you place an order with us, we collect the personal information that you provide to us, such as your billing and payment information. You may also have the option to store credit card or other payment information to make it easier to purchase products or service from the Website in the future. If you contact our member services agents, you may also provide us with personal information that we collect. When you purchase a product or service, we collect all of your order information, such as the type of product you purchased and the costs of each product. We may provide you with the opportunity to review our products or participate in public forums associated with the Website. Any reviews, posts or comments will be public, so you should use care before posting information about yourself online.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Information about your health or medical history that you provide in a health insurance application.
• Your responses to surveys that we might ask you to complete for research purposes.
• Your search queries on the Website.
• Information You provide on a member portal or provided on your behalf on an agent or broker portal.

You also may provide information to be published or displayed (hereinafter, “posted“) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. While the Company has security measures, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

FirstCall obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete, and products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies.
• From our third-party business partners, such as insurance agents and brokers, medical providers and service providers.

Information We Collect Through Automatic Data Collection Technologies 

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Click here https://allaboutdnt.com, for information on how you can opt out of behavioral tracking on this Website and other mechanisms that enable consumers to exercise choice about behavioral tracking.

The information we collect automatically is statistical data and may include personal information that we may maintain or associate with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.
• Use cookies.

The technologies we use for automatic data collection may include:

Browser Cookies. A browser cookie is a small file placed on the hard drive of your computer. By using our Website, you consent to our placement of cookies on your computer. You may occasionally get cookies from our business partners or other third parties. We have no access to or control over these cookies. You may refuse to accept browser cookies by activating the appropriate setting on your browser. Please consult your browser’s “help” section for instructions. Additionally, if you have an Adobe Flash player installed on your computer, your Flash player can be set to reject or delete Flash cookies. If you choose to decline cookies, you may not be able to fully experience the features of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

We use Google Analytics, a web analysis service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses Cookies that are stored on your computer and allow for an analysis of your website use. The information generated by the Cookies about your use of our Website is forwarded to Google and stored on servers located in the USA.

You may opt out from the use of Cookies by changing your browser settings. You may also deactivate the service by downloading and installing the browser add-on to deactivate Google Analytics for your current browser, available at: https://tools.google.com/dlpage/gaoptout/.

For further information, please visit https://policies.google.com/.

For further information about managing and disabling cookies on your computer, see www.allaboutcookies.org/manage-cookies.

Third-Party Use of Cookies

Some content or applications, including advertisements, on the Website are provided by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information, below.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. The following mechanisms may provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Solicitations from the Company. If you do not wish to have your email address/contact information used by the Company to solicit your business with FirstCall, you can opt-out by sending an email to: info@FirstCalltelemed.com. If we have sent you a solicitation email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, product service experience, or other transactions.
• Communications from the Company. You will still receive communications from us regarding your insurance quote, application, policy or advanced premium tax credit even if you opt out of receiving our surveys and/or notices of additional products and services.

How We Use Your Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To present our Website and its contents to you.
• To provide you with information, products, or services you request from us.
• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To provide you with notices about your account, including expiration and renewal notices.
• To notify you about changes to our Website or any products or services we offer or provide through it.
• To help find you, and if you choose to do so, apply for health insurance and other products that may be of interest to you and your family.
• To allow you to participate in any interactive features on our Website.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To evaluate or conduct a potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of FirstCall’s assets, whether as a going concern or as part of a similar proceeding, in which personal information held by FirstCall about our Website users is among the assets transferred.
• To fulfill any other purpose for which you provide it.
• For any other purpose with your consent.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

FirstCall will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

FirstCall may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

We share your personal information with the following categories of third parties:

• To our subsidiaries and affiliates.
• To contractors, service providers, data aggregators, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• Medical providers.
• Your chosen insurance company and/or health care sharing ministry (HCSM).
• Insurance agents, brokers, and business partners.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it. For example, if you give us your email address as part of completing a form on the Website or calling our sales center, we may use your email address or other personal information provided to contact you.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use, https://firstcalltelemedicine.com/term-of-use/, and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of FirstCall, its customers, or others.

Your request for products:

If you request to be contacted about any type of insurance product or health care sharing ministry program, request to be contacted by a licensed agent or other representative, request assistance with enrolling in any type of insurance product or health care sharing ministry program or make any other request for someone to contact you (such as by filling out an online request form), then our agents or representatives may contact you, or we may disclose your personal information to a third-party insurance agency, insurance agent, insurance company or other appropriate entity, so that such entity may contact you about any product in which you indicated interest or may assist you in enrolling in any such product. Any additional information that you subsequently choose to provide to any third-party entity will be governed by that entity’s privacy policy.

Your request to cancel:

Cancellation of Service – You can cancel your telemedicine service at any time by contacting FirstCall Customer Care at 1-866-920-DOCS. Once canceled, the FirstCall telemedicine service will not renew and you will receive a confirmation email at the email address on file. If you have any additional questions about the cancellation process, please contact the Customer Care Team:

FirstCall Customer Care

Phone: 1-866-920-DOCS

Email: CustomerCare

CustomerCare@firstcalltelemed.com

Providing you with a quote or processing your application:

We may use your personal information to get in touch with you when necessary to process your application or to provide you with a quote. For example, emails may be sent to you throughout the application process to inform you of the status of your application and to seek additional information that is requested as part of the application. We may also use phone numbers you provide to send you telephone or text messages about your application or account, and such messages may be automatically sent with an autodialer, an artificial or prerecorded voice, or other automation technology.

Customer satisfaction, referrals and other products:

We or our affiliates may contact you to survey your satisfaction with our service, refer our products and services to other people, and/or to inform you of additional products and services. You may opt-out of receiving these additional communications from us by following the opt-out procedures below or as set out in the emails we send to you, as applicable.

California Residents – Your Rights and Choices

The CCPA provides certain consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Disclosures of Personal Information for a Business Purpose:

In the preceding twelve (12) months, FirstCall has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

We disclose your personal information for a business purpose to the following categories of third parties, including within the last 12 months:

• To our subsidiaries and affiliates.
• To contractors, service providers, data aggregators, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• Medical providers.
• Your chosen insurance company and/or HCSM.
• Insurance agents, brokers, and business partners.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it. For example, if you give us your email address as part of completing a form on the Website or calling our sales center, we may use your email address or other personal information provided to contact you.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use, https://firstcalltelemedicine.com/term-of-use/, and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of FirstCall, its customers, or others.

Sales of Personal Information:

In the preceding twelve (12) months, FirstCall has sold the following categories of personal information:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

We sell your personal information to the following categories of third parties:

• Data aggregators
• Advertising and marketing organizations
• If you do not want your personal information sold, please send a message to info@firstcalltelemed.com.

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:

California Consumer Privacy Act Request FirstCall.com/ccpa

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by emailing info@firstcalltelemed.com.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

You have the right to request that FirstCall disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request to info@firstcalltelemed.com, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we disclosed your personal information for a business purpose, identification of the personal information categories that each category of recipient obtained.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

You have the right to request that FirstCall delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request to info@firstcalltelemed.com, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights:

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at info@FirstCalltelemed.com.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please email us at info@FirstCalltelemed.com and provide us with legally acceptable evidence of your authorization to act on another’s behalf.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. [However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.]

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. Specifically, we may transmit your personal information in Excel format.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Accessing and Correcting Your Information

If you are not a California resident, you can review and change your personal information by logging into the Website and visiting your account profile page.

You may also send us an email at info@firstcalltelemed.com to request access to or correct any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use, https://firstcalltelemedicine.com/term-of-use/.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We maintain reasonable physical, electronic, and procedural safeguards designed to help us protect your non-public personal information against loss, misuse, disclosure and alteration. For example, we use Secure Socket Layer (SSL) technology to encrypt your credit card information when you purchase products through our Website. When you establish an account at FirstCall, a password is generated to help protect your account information. Passwords can be updated. A password is only as strong as you make it. You should select a unique password and keep it safe. You may change your password as often as you wish by going to the Member Log In link of the Website.

Changes to Our Privacy Policy

FirstCall reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. The date the Privacy Policy was last revised is identified at the top of the page. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting our Website and this Privacy Policy to check for any changes.

Contact Information

If you have any questions or comments about this notice, the ways in which FirstCall collects and uses your information and in the FirstCall Website Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Email:
info@FirstCalltelemed.com